1608 SPRING HILL ROAD, SUITE 400 • VIENNA, VIRGINIA • 22182 • 703.893.6600 • FAX 703.821.8236

M E M O 

DATE: November 12, 2013 

TO: Subcommittee for Procedures Review 

FROM: U. Hans Behling 

SUBJECT: PER-014 Review Findings #1 and #3 

As a follow-up to the Procedures Review Subcommittee teleconference on November 7, 2013, 

and at the direction of the Subcommittee, SC&A reviewed the employment periods of 

Construction Trade Workers (CTWs) at the Rocky Flats facility, which is the only facility for 

which CTW employment periods are available. 

The purpose of this review is linked to Finding #1 (Conditional) (as well as Finding #3) cited by 

SC&A in our review of OCAS-PER-014, Construction Trades Workers, dated March 2012. 

Summaries for Finding #1 (Conditional) and Finding #3 (Conditional) are enclosed herein as 

Exhibit #1. 

Our review consisted of assessing the employment periods of CTWs in order to determine if 

employment periods were substantially less than a full year. Annual employment periods 

substantially less than 1 year for CTWs would invalidate comparisons of the 95th percentile 

values of annual deep dose between CTWs and all monitored workers (AMWs) and raise 

potential concerns about the validity of the 1.4 adjustment factor. 

A full review for all years (1953–2005) is beyond the scope of this effort. Correspondingly, our 

review was limited to 3 years: 1970, 1977, and 1978. 

1970 Data 

CTW employment data for 1970 was presented by ORAUT during the teleconference on 

November 7, 2013, and is enclosed herein as Exhibit #2. Inspection of Exhibit #2 identifies 

three highlighted columns. The first two highlighted columns (F and G) are the “Begin” and 

“End” dates of each CTW worker in 1970. The third highlighted column (Column I) represents 

the fraction of the year during which the CTW was employed. For example, [redacted].

For 1970, there were a total of 60 CTWs at the Rocky Flats facility whose employment ranged 

from 0.2 year to essentially a full year (i.e., 0.99726). A breakdown of employment periods for 

1970 is shown in Table 1. When weighted, the average CTW worker for 1970 was employed for 

0.908 year. 
Memo: PER-014 Review Findings 1 and 3 2 SC&A – November 12, 2013 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Table 1. Distribution of Employment Duration (Fraction of Year) for 

Construction Trades Workers for 1970 at Rocky Flats Plant

No. of CTWs Fraction of Year Employed

1 [redacted]

1 [redacted]

5 [redacted]

1 [redacted]

1 [redacted]

1 [redacted]

50 0.9973

Total CTW = 60 Avg. CTW Employment = 0.908

Based on the 1970 data alone, SC&A would fully agree that an average annual employment 

period of 0.908 year for CTWs approximates “full-time” employment or the average 

employment period of AMWs. 

1977 and 1978 Data 

Our review of CTW employment data for 1977 and 1978 revealed significantly different values. 

Due to the large number of CTWs for each of these years, raw data sheets are not included herein 

but may be verified by accessing the spreadsheet “Construction_External_Dosimetry_RFP_ 

CTW.xls”.

Presented in Table 2 and Table 3 below are summary data for each of the two years. Inspection 

of Table 2 shows that for 1977, there were 665 CTWs whose employment ranged from 

0.9178 year to 0.1534 year with a weighted average of 0.51 year or about 6 months. 

For 1978, Table 3 shows that a total of 855 CTWs were employed at Rocky Flats for 

employment periods ranging from 0.9973 year to 0.2520 year with a weighted average of 

0.474 year (or less than 6 months). 

Table 2. Distribution of Employment Duration (Fraction of Year) for 

Construction Trades Workers for 1977 at Rocky Flats Plant

No. of CTWs Fraction of Year Employed

5 0.9178

230 0.7516

1 0.5890

1 0.5123

163 0.5068

40 0.5041

1 0.3370

2 0.2603

165 0.2575

3 0.2547

21 0.2521

1 0.1616

1 0.1534

Total CTWs = 665 Avg. CTW Employment = 0.51
Memo: PER-014 Review Findings 1 and 3 3 SC&A – November 12, 2013 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Table 3. Distribution of Employment Duration (Fraction of Year) for 

Construction Trades Workers for 1978 at Rocky Flats Plant

No. of CTWs Fraction of Year Employed

1 0.9973

2 0.9178

2 0.7589

297 0.7561

1 0.6219

92 0.50685

50 0.5041

272 0.2548

138 0.2520

Total CTWs = 855 Avg. CTW Employment = 0.474

It should also be noted that large groups of workers were hired on identical dates for fixed 

periods of employment. For example, Table 3 shows that 272 CTWs had a common yearly 

fraction of 0.2548. The spreadsheet data for year 1978 shows that all of the 272 CTWs were 

hired on June 29, 1978, and terminated September 30, 1978, which supports SC&A’s contention 

that CTWs are frequently hired for specific tasks of limited duration. 

In summary, SC&A stands by its conditional Finding #1(as well as Finding #3) that annual 

employment periods for CTWs differ sufficiently from AMWs. In turn, the recommended deep 

dose adjustment factor of 1.4 may not be claimant favorable. In addition, there may be a need 

for a shallow dose adjustment factor. 
Memo: PER-014 Review Findings 1 and 3 4 SC&A – November 12, 2013 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

EXHIBIT #1: SUMMARY OF FINDINGS #1 and #3 (CONDITIONAL) 

FROM SC&A’S REVIEW OF OCAS-PER-014 

2.3 SC&A’S COMMENTS, OBSERVATIONS, AND FINDINGS PERTAINING TO 

ORAUT-OTIB-0052 AS THE PRINCIPAL SUPPORT DOCUMENT FOR OCASPER-014 

2.3.1 External Penetrating Dose Adjustment Factor 

Guidance for the reconstruction of external penetrating dose for unmonitored CTWs involves the 

use of a 1.4 adjustment factor (i.e., multiplier) and the 95th percentile, site-specific coworker 

dose. Based on dose data that compared CTW to AMW doses for six DOE sites, NIOSH’s 

selection of the 1.4 adjustment factor for all DOE facilities and for all years appears to be 

conservative and claimant favorable. 

At this time, SC&A has neither been given access to the original dose data nor an explanation 

that would indicate whether the annual doses for CTWs and AMWs were scaled to reflect 

exposure/employment duration in any given year. Unlike “all monitored workers” who mostly 

represent full-time employees/workers at a site, CTWs are more likely to be hired on an asneeded basis and for restrictive time periods that may represent a small fraction(s) of a given 

year. 

Finding #1 (Conditional): The Deep-Dose Adjustment Factor of 1.4 May Not be Claimant 

Favorable. In the event that annual doses for CTWs (and to a lesser extent for AMWs) were not 

adjusted to account for exposure/employment periods of less than a full year, the recommended 

deep-dose adjustment factor of 1.4 may not be claimant favorable. 

Finding #2 (Conditional): The Inclusion of CTWs Among AMWs May Obscure Dose 

Differences. As stated in Section 4.0 of OTIB-0052, “. . . Sometimes the AMW group includes 

the CTWs and in others it did not.” However, the OTIB does not identify which data sets (i.e., 

external deep dose, shallow dose, and/or bioassay data sets) failed to separate CTW from AMW 

data. 

A review of external data contained in Tables 5-1, 5-2, 5-3, 5-4, and 6-1 of OTIB-0052 identifies 

the following: 

(1) The number of monitored CTWs relative to AMWs represents a substantial fraction of 

AMWs. 

 (2) A ratio of “number monitored” to “number with measurable dose” among CTWs is 

consistently lower than those for AMWs. 
Memo: PER-014 Review Findings 1 and 3 5 SC&A – November 12, 2013 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

EXHIBIT #1 (Continued)

The inclusion of CTWs among AMWs, therefore, obscures the true ratios of CWTs/AMWs in 

instances where AMWs represent a combination of CTWs and non-CTWs. 

2.3.2 External Shallow Dose 

Only two of the eight DOE sites (i.e., SRS and Rocky Flats) provided annualized shallow dose 

data for deriving CTWs/AMWs dose ratios. According to NIOSH, these limited data, 

nevertheless, suggest that AMW doses consistently bounded CTW doses and obviate the need 

for an adjustment factor. 

Finding #3 (Conditional): A Shallow-Dose Adjustment Factor May be Required. Annual shallow 

doses (like penetrating doses) received by CTWs may, nevertheless, have been understated in the 

event that NIOSH failed to adjust CTW shallow doses to account for employment/exposure 

periods of less than 1 year as was cited in Findings 1 and 2 above for penetrating dose 

assessment. 

If Finding #1 holds and there are significant differences in exposure times between CTWs and 

AMWs in any given year, an adjustment factor may be required for the reconstruction of shallow 

dose for CTWs. 
Memo: PER-014 Review Findings 1 and 3 6 SC&A – November 12, 2013 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

EXHIBIT #2: CTW EMPLOYMENT DATA FOR 1970

1 Year HS ID Deep Skin Expid Begin End Company Fraction

2 1970 57 57 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

3 1970 323 373 [redact] [redact] [redact] KAISER-HILL COMPANY, L.L.C. [redact]

4 1970 230 230 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

5

6 1970 379 379 [redact] [redact] [redact] J A JONES CONSTRUCTION\3893 [redact]

7 1970 100 100 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

8 1970 31 31 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

9 1970 47 47 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

10

11 1970 199 199 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

12 1970 653 881 [redact] [redact] [redact] J A JONES CONSTRUCTION\3893 [redact]

13

14 1970 320 320 [redact] [redact] [redact] SWINERTON & WALBERG COMPANY [redact]

15 1970 385 385 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

16 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

17 1970 441 441 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

18 1970 345 345 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

19

20 1970 363 363 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

21 1970 76 76 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

22 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

23 1970 101 101 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

24 1970 224 224 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

25 1970 392 392 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

26

27 1970 1438 1438 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

28 1970 146 146 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

29 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

30 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

31 1970 21 21 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

32 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

33 1970 130 130 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

34 1970 0 0 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

35

36 1970 342 342 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

37 1970 0 0 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

38 1970 190 190 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

39 1970 19 19 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

440 1970 804 804 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

41 1970 344 344 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

42 1970 856 856 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

43 1970 1302 1302 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

44 1970 405 405 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

45 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726
Memo: PER-014 Review Findings 1 and 3 7 SC&A – November 12, 2013 

NOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

EXHIBIT #2 (Continued)

Year HS ID Deep Skin Expid Begin End Company Fraction

46 1970 299 299 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

47 1970 229 229 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

48 1970 220 220 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

49 1970 749 749 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

50

51 1970 83 83 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

52 1970 269 269 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

53 1970 72 72 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

54 1970 0 0 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

55 1970 236 251 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

56 1970 211 211 [redact] 1-Jan-70 31-Dec-70 SWINERTON & WALBERG COMPANY 0.99726

57 1970 201 201 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

58 1970 152 152 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

59 1970 488 488 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

60 1970 182 182 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

61 1970 0 0 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

62 1970 152 152 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

63 1970 430 430 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

64 1970 392 392 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

65 1970 458 458 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

66 1970 38 38 [redact] 1-Jan-70 31-Dec-70 J A JONES CONSTRUCTION\3893 0.99726

67

68

69

70

71

72 1970 1496 1496 [redact] 1-Jan-70 31-Dec-70 KAISER-HILL COMPANY, L.L.C. 0.99726

73 1970 137 137 [redact] 1-Jan-70 31-Dec-70 KAISER-HILL COMPANY, L.L.C. 0.99726